Important Regulatory Information
Sloane Robinson LLP is established as a Limited Liability Partnership in England and Wales (No. OC309313) with its registered office at 36 Queen Street, London. EC4R 1BN. Sloane Robinson LLP is authorised and regulated by the Financial Conduct Authority in the United Kingdom (Firm Reference Number 409159).
Important Jurisdictional Regulatory Information
For jurisdictional regulatory information please access the Important Jurisdictional Regulatory Notice here.
Sloane Robinson LLP has documented the disclosures required by the FCA under BIPRU 11.3. These are available on the firm’s website (under the news section) for registered users or from the Compliance Officer at the registered office.
UK Stewardship Code
Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Sloane Robinson LLP (the "Firm") is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.
The Firm has a proxy voting policy in place, as required by the Hedge Fund Standards Board, which sets out the circumstances in which the Firm will vote on behalf of clients. The Firm also has a conflicts of interest policy in place to manage the risks of any conflicts of interest arising between itself and its clients and has in place procedures to deal with any conflicts that arise. These policies and procedures are regularly reviewed and updated.
The Firm invests in a variety of asset classes and in a variety of jurisdictions globally. The Firm takes a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests, in accordance with its proxy voting policy, and, consequently, does not consider it appropriate to commit further to any particular voluntary code of practice relating to any individual jurisdiction. This approach will be kept under review.
Under FCA rules, Sloane Robinson is required to take all reasonable steps to obtain the best possible result when executing client orders or placing orders with (or transmitting orders to) other entities for execution, taking into account a range of execution factors, including price, costs, speed, size, nature of the order, likelihood of execution and settlement, and any other consideration relevant to the execution of the order. Further details of Sloane Robinson's Best Execution Policy are available on request.
Financial Crime Statement
We seek to comply with high standards of anti-money laundering, counter terrorist financing practice, anti bribery and economic sanctions in all our business dealings. We take our duty of compliance extremely seriously and have established strong policies and procedures to manage these issues, including awareness training, record keeping and compliance monitoring. We value our reputation for ethical behaviour and recognise that over and above the commission of any crime any involvement in bribery or corruption would of itself be unacceptable. We absolutely forbid corruption and the paying or receipt of bribes.
Sloane Robinson Policies
Sloane Robinson maintains various policies and procedures to ensure the proper provision of services to clients, including in relation to the management of conflicts of interest, personal account dealing, anti-bribery and money laundering, order allocation and resolution of dealing errors. Further details of these policies are available on request. Please note that Sloane Robinson’s policy on the resolution of dealing errors has recently been updated. The key points of the policy are: (1) losses associated with a dealing error for which Sloane Robinson is contractually responsible will be borne by the firm and (2) gains resulting from a dealing error will be credited to and retained by the client.